When executing transactions on behalf of funds that Alter Domus Management Company S.A. manages (hereafter Client Funds), Alter Domus Management Company S.A. takes all reasonable steps to obtain the best possible results for the Client Funds or the investors in the Client Funds, where applicable. Alter Domus Management Company S.A. takes into account factors such as the characteristics of the order (eg price, costs, speed, order size and nature), the financial instruments subject to the order, the execution venues and the investment policy of the Client Funds.

Alter Domus Management Company S.A. monitors and reviews the best execution policy on a regular basis and ensures the effectiveness of its processes, in order to identify and, where appropriate, correct any deficiencies.

Voting Rights Policy

Alter Domus Management Company S.A. applies adequate and effective strategies for determining when and how voting rights attached to securities held in the portfolios of Client Funds.

Voting rights are exercised exclusively to the benefit of the Client Funds or the investors of the Client Funds, where applicable.

Alter Domus Management Company S.A. monitors corporate events relating to the exercise of voting rights on a regular basis. Issues being voted at shareholder meetings are evaluated on a case by case basis.

Conflict of Interest Policy

Alter Domus Management Company S.A. is committed to investigate and monitor potential conflicts of interest that may arise within Alter Domus Management Company S.A. and within the Client Funds or the investors in the Client Funds, where applicable.

Alter Domus Management Company S.A. has set a process whereby potential circumstances of conflicts of interests are monitored, and where necessary disclosed to the Client Funds of the investor of Client Funds, where applicable.

A compliance officer of Alter Domus Management Company S.A. is in charge of the above-mentioned duties relating to the conflicts of interest monitoring.

Complaints Handling Policy

Alter Domus Management Company S.A. has implemented procedures for managing customer complaints relating to the services of Alter Domus Management Company S.A.

This procedure is simple, objective and transparent. In this process Alter Domus Management Company S.A. investigates all relevant information in order to correct root causes and improve processes.

The staff of Alter Domus Management Company S.A. has been trained to resolve and deal with complaints within a reasonable time. A written acknowledgement of receipt of a complaint will be provided within 5 business days and a detailed answer will be sent within a month (where an answer cannot be provided within this period, the cause of the delay and an estimated finalisation date shall be provided).

The name and contact details of the person in charge of the complaint file, as well as the name and contact details of a person assigned to the case at the management level will be provided. This will allow the complaint to be raised to the management level, in case the answer is not satisfactory.

In a case where Alter Domus Management Company S.A. would not provide a satisfactory answer, the complaint can be filed directly to the CSSF (the Luxembourg supervisor of the financial sector), for an out-of-court resolution. A form to facilitate a direct complaint to the CSSF can be found on the CSSF website. (www.cssf.lu)

Ensure that remuneration is in line with the business strategy, objectives, values and interests of Alter Domus Management Company S.A., the Client Funds, or the investors of the Client Funds, where applicable;

Not encourage risk‐taking which is inconsistent with the risk profiles, rules or articles of incorporation or management regulations of the Client Funds;

Ensure consistency with and promotion of sound and effective risk management to avoid excessive risk taking;

Avoid or manage conflicts of interest.

The variable component of remuneration should at all times be reasonable compared to the fixed component of the remuneration. Remunerations to be applied shall always provide for appropriate balance between fixed and variable remuneration elements and should be in line with the business strategy, objective, value and interest of Alter Domus Management Company S.A. The maximum limit of the variable component of the remuneration does in principle not exceed 100 % of the annual gross salary of the employee.

The amount of the remuneration of employees of Alter Domus Management Company S.A. is approved under the responsibility of the board of directors of Alter Domus Management Company S.A. in accordance with the remuneration policy and in compliance with applicable laws and regulations.

The total amount of remuneration is based on a combination of the assessment of the performance of the individual, the business unit concerned and the overall results of Alter Domus Management Company S.A.

Alter Domus Management Company S.A. may perform an “ex‐post risk adjustment” of the variable remuneration, in presence of certain factors (such as for example but not limited to, evidence of misbehavior or serious error by the person in scope; significant downturn in the financial performance or a significant failure of risk management in Alter Domus Management Company S.A. in its relevant business unit; significant change in Alter Domus Management Company S.A.’s financial situation and in general when the bonuses have been based on fraudulent data) which may lead to the mandatory reimbursement or the total or partial cancellation of bonuses awarded to the person in scope.

Bonus shall not be offered if they cause conflicts of interest, specifically regarding the ability of Alter Domus Management Company S.A. to have sound risk management and clients’ and investors ‘protection principles in place.

ABOUT US

Alter Domus is a fully integrated Fund and Corporate services provider, dedicated to international private equity & infrastructure houses, real estate firms, private debt managers, multinationals, capital markets issuers and private clients. Our vertically integrated approach offers tailor-made administration solutions across the entire value chain of investment structures, from fund level down to local Special Purpose Vehicles.
Founded in Luxembourg in 2003, Alter Domus has continually expanded its global service offer and today counts 40 offices and desks across five continents. This international network enables clients to benefit globally from the expertise of more than 2,000 experienced professionals active in fund administration, corporate secretarial, accounting, consolidation, tax and legal compliance, depositary services and debt administration services.
We are proud to serve 17 of the 20 largest private equity houses, 15 of the 20 largest real estate firms and 17 of the 20 largest private debt managers in the world.